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US Shareholder of a Canco After 2017 Tax Reform

Posted By: Milosz Zak on October 31, 2018 at 2:00:08 in Articles

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Please see Sunita Doobay’s latest article for the Canadian Tax Foundation’s newsletter Canadian Tax Highlights which concerns Public Law no. 115-97 (2017 tax act) — the Tax Cuts and Jobs Act, signed into law on December 22, 2017, which significantly changed the Code and negatively affects a US person in Canada holding shares in a closely held corporation.

US Shareholder of a Canco After 2017 Tax Reform

Sunita Doobay is licensed in Canada and the United States. She is admitted in New York (State of New York. Supreme Court, Appellate Division. Third Judicial Department) and in Ontario (Law Society of Upper Canada), to the U.S. Tax Court and to the U.S. Court of International Trade. She is a fellow of the American Bar Foundation. She also holds the trust and estates tax practitioner designation. She chairs the Net Investment Income Tax committee for the American Chamber of Commerce (AMCHAM) in Toronto. She holds a Master in U.S. Taxation from New York University and sits on the advisory council of its international taxation LL.M. program. Her LL.B. is from Queen’s University.

As a U.S. tax lawyer and a Canadian tax lawyer with over 20 years of experience, she is uniquely qualified to advise clients investing in the United States and vice versa Americans investing in Canada. Her practice also includes advising entertainers on co-production agreements and utilizing the availability of the film tax credit. She is the present co-chair of the International Tax Committee of the American Bar Association Section of International Law as the well as the editor of the tax portion of the Section International Law Year in Review. She is the co-author of the Annotated Partnerships Act of Ontario published by Carswell, Thomson Reuters.

As an active member of the American Bar Foundation, International Fiscal Association and the Canadian Tax Foundation, she speaks and publishes frequently on cross border tax and estate planning issues.

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